PPACA gives consumers an automatic right to a special enrollment period from April 1 through Nov. 15, the start of the 2015 open enrollment period, if they have gone through a major life change, such as the loss of a job, or if they qualify for an exemption from the deadline due to “limited circumstances.”

The list of limited circumstances includes “exceptional circumstances,” such as earthquakes, hurricanes, medical emergencies, or exchange system outages; exchange enrollment system errors, such as immigration status system errors, and unresolved efforts to get an exchange caseworker to handle an enrollment problem.

Officials refer to agents, brokers and insurance companies in a section on applying for special enrollment periods due to “misinformation, misrepresentation or inaction.”

Officials refer to navigators, certified application counselors and exchange call center representatives in the same section.

A consumer could ask for a special enrollment period if one of those individuals or entities failed to enroll the consumer in a plan, enrolled a consumer in the wrong plan, or failed to get the consumer access to the right coverage subsidies, officials say.

HHS officials announced yesterday that they will give HHS exchange users who say they started the plan enrollment process by March 31 until mid-April to ask for a special enrollment period without providing documentation of the reasons for the request. CCIIO officials describe how HHS will handle the March 31 deadline here.